On behalf of the San Antonio Independent School district (the "school district"), you ask that
we reconcile two conflicting open records rulings, Open Records Letter Nos. 1350 (1999)
and 1249 (1999). Your request was assigned ID# 126726.

Both of the referenced rulings concern the required public release of the same resource class
student roster. However, the two ruling reached different conclusions, with Open Records
Letter No. 99-1249 (1999) finding that the roster is a confidential education record under the
Family Education Rights and Privacy Act ("FERPA"), 20 U.S.C. § 1232g, and Open Records
Letter No. 99- 1350 (1999) finding that the roster, with the grades and identification numbers
redacted, is directory information, which may be released after the school district complied
with federal notice requirements. 20 U.S.C. § 1232g (a)(5)(A); see Open Records Decision
No. 244 (1980).

We now conclude that Open Records Letter No. 99-1350 was in error. Because it concerns
students in a resource class, the roster is not directory information but is a confidential
education record under FERPA. See 20 U.S.C. § 1232g(a)(5)(A). Accordingly, Open
Records Letter No. 99-1350 is overruled in accordance with this decision.

We are resolving this matter with this informal letter ruling rather than with a published open
records decision. This ruling is limited to the particular records at issue under the facts presented to us in this request and may not be relied upon as a previous determination
regarding any other records. If you have questions about this ruling, please contact our
office.